Peter J. Bresson v. Commissioner

111 T.C. No. 6

UNITED STATES TAX COURT PETER J. BRESSON, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22824-96. Filed August 19, 1998. In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $329,000 to an unrelated third party. Petitioner kept the proceeds from the sale. On Mar. 5, 1993, J filed a tax return for its fiscal year ended Feb.…